People of Michigan v. Clifton Shary-Shmorree-L Witherspoon, 329964

Defendant was interviewed under oath about a 2013 homicide; he stated he went to the Chicken Coop and was driven to a bar by "Trenton," and admitted being intoxicated that night.
Other witnesses contradicted defendant’s statements, and he was charged with perjury under MCL 767A.9(1)(b); charged also as a fourth-offense habitual offender.
Before trial defendant sent letters to judges claiming improper discovery handling and accusing counsel and the prosecutor of conspiring against him.
At a July 6, 2015 hearing defendant told the court he wanted substitute counsel because he had not received full discovery; the court denied the request and ordered counsel to provide outstanding materials.
Trial proceeded; a jury convicted defendant of perjury and he was sentenced. Defendant appealed, arguing the trial court abused its discretion by refusing to substitute counsel without a more thorough inquiry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying defendant’s request to substitute appointed counsel without further inquiry	The prosecution (People) argued the court acted within discretion because defendant did not show good cause for substitution	Withdrew counsel, defendant argued court failed to make adequate factual inquiry regarding his complaints and therefore should have allowed substitution	Court affirmed: no abuse of discretion. Defendant did not show good cause or a factual dispute requiring extensive inquiry

People v. Strickland, 293 Mich. App. 393 (court's discretion and standard for substitution of counsel) (2011) (trial court must hear claim and make findings if factual dispute exists)
People v. Yost, 278 Mich. App. 341 (discretion abuse standard) (2008)
People v. Russell, 471 Mich. 182 (Sixth Amendment counsel principle) (2004)
People v. Mack, 190 Mich. App. 7 (good cause standard for substitute counsel) (1991)
People v. Buie, 298 Mich. App. 50 (scope of judicial inquiry and affirmance where record shows counsel was attentive) (2012)
People v. Ginther, 390 Mich. 435 (appellate review when trial court did not consider allegation; counsel attentiveness standard) (1973)